Sri.Jose Kuruvinakunnel, Kottayam V. The ITO, Kottayam

MA 145/COCH/2013

• Counselvise Citation: [2014] 111 COUNSELVISE.COM (IT) 0496 (ITAT-COCHIN)
• Duration Of Justice: 1 month(s) 29 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 07-02-2014
• Appeal Filed By: Assessee
• Bench Allotted: DB
• Assessment Year: 1999-2000
• Appeal Filed On: 09-12-2013
• Court: TRIBUNAL
• Department Lawyers: M ANIL KUMAR
• Assessee Lawyers: K I JOHN
• Keywords: Principle of natural justice
• Section: 254(2); 13; 22; 68

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN BEFORE S/SHRI N.R.S.GANESAN, JM AND B.R.BASKARAN, AM M.P. NOS. 142-145/COCH/2013 (ARSG. OUT OF I.T.A. NOS. 429-432/COCH/2005) ASSESSMENT YEARS : 1996-97 TO 1999-2000 JOSE KURUVINAKUNNEL, PARTNER, HOTEL MAYURA, POOVARANI, PALA, KOTTAYAM. VS. THE INCOME-TAX OFFICER, WARD-2, KOTTAYAM. (ASSESSEE-APPELLANT) (REVENUE-RESPONDENT ) ASSESSEE BY SHRI K.I. JOHN, CA REVENUE BY SHRI M. ANIL KUMAR, CIT(DR) DATE OF HEARING 24/01/2014 DATE OF PRONOUNCEMENT 07/02/2014 O R D E R PER B.R.BASKARAN, ACCOUNTANT MEMBER: THE ASSESSEE HAS FILED THESE MISCELLANEOUS APPLI CATIONS WITH THE PLEA THAT THERE ARE MISTAKES APPARENT FROM RECORD IN THE COMMON ORDER D ATED 20-09-2013 RELATING TO THE ASSESSMENT YEARS 1996-97 TO 2000-01 PASSED BY THE T RIBUNAL IN THE HANDS OF THE ASSESSEE AND THEY REQUIRE RECTIFICATION U/S 254(2) OF THE AC T. 2. THE FIRST MISTAKE POINTED OUT BY THE ASSESSE E, WHICH IS DISCUSSED IN PARAGRAPH 1 TO 5 OF THE PETITION, IS THAT THE TRIBUNAL DID NOT GIVE REASONS AS TO WHY THE DECISION OF THE APEX COURT REPORTED IN 292 ITR 682 IS NOT APPLICABLE, I. E., ACCORDING TO THE ASSESSEE, THE TRIBUNAL HAS SIMPLY STATED THAT THE SAID DECISION IS NOT APP LICABLE, WITHOUT GIVING ANY REASONS. A SIMILAR CONTENTION WAS RAISED IN RESPECT OF SOME OT HER CASE LAWS ALSO. THE LD COUNSEL ALSO STRONGLY PLACED RELIANCE ON THE DECISION OF HONBLE PUNJAB AND HARYANA HIGH COURT RENDERED IN THE CASE OF ATM FORGINGS VS. CIT (2013)(359 ITR 314)(P & H), WHEREIN THE HIGH COURT, BY FOLLOWING THE DECISION OF HONBLE SUPREME COURT IN THE CASE OF KRANTI ASSOCIATES P LTD VS. MASOOD AHMED KHAN (2010)(9 SCC 496), HAS HELD THAT THE TRIBUNAL HAS GOT A DUTY TO RECORD REASONS FOR ITS ORDER. THE LD A.R ALSO PLACED RELI ANCE ON THE DECISION OF HONBLE MADHYA PRADESH HIGH COURT IN THE CASE OF CIT VS. BRIGHT AU TOMATIVE AND PLASTICS LTD (2006)(280 ITR M.P. NOS.142-145/COCH/2013 2 157) AND SUBMITTED THAT MERE MENTIONING OF THE CASE LAWS IN THE ORDER IS OF NO CONSEQUENCE BECAUSE IT DOES NOT SERVE ANYBODYS PURPOSE. 3.1 WE NOTICE THAT THE TRIBUNAL HAS NOTED DOWN V ARIOUS CASE LAWS RELIED UPON BY THE ASSESSEE AND UPON GOING THROUGH THE SAME, THE TRIBU NAL CAME TO THE CONCLUSION THAT THEY ARE NOT APPLICABLE TO THE FACTS OF THE INSTANT CASE AND HENCE IT WAS NOT CONSIDERED NECESSARY TO DISCUSS ABOUT THE FACTS PREVAILING IN THOSE CASES AND THEIR INAPPLICABILITY TO THE INSTANT CASES. IN THIS REGARD, WE MAY MENTION HERE THAT THE ISSUE CONTESTED BEFORE THE TRIBUNAL WAS ABOUT THE OWNERSHIP OF THE DEPOSITS MA DE INTO A BANK ACCOUNT STANDING IN THE NAME OF A PERSON NAMED SHRI FRANCIS JOSEPH AND THE SAID ISSUE SURROUNDED MAINLY ON THE PECULIAR FACTS ATTACHED THERETO. THE TAX AUTHORITI ES HAD ALSO REACHED CONCLUSIONS ON THE BASIS OF FACTS AND HENCE, THE TRIBUNAL HAS ALSO ADJ UDICATED THE ISSUE BY DULY CONSIDERING ALL THE FACTS AND CIRCUMSTANCES SURROUNDING THE SAME. THE CASE LAW RELIED UPON BY THE ASSESSEE WAS CONSIDERED AS NOT GERMANE TO THE FACTS SURROUNDING THE ISSUE AND HENCE THE TRIBUNAL DID NOT DISCUSS ABOUT THE SAME. AT THIS JU NCTURE, WE MAY MENTION THAT THE TRIBUNAL HAS RENDERED ITS DECISION BY KEEPING IN MIND THE ES TABLISHED LEGAL PRINCIPLES THAT THE DECISION RENDERED BY THE NON-JURISDICTIONAL HIGH CO URTS HAVE PERSUASIVE VALUE AND FURTHER WHAT IS BINDING IS ONLY THE RATIO OF THE DECISION. 3.2 ACCORDING TO LD A.R, THE FAILURE OF THE TRIB UNAL TO DISCUSS ABOUT THE CASE LAWS RELIED UPON BY THE ASSESSEE WOULD RENDER THE ORDER ERRONEO US. WE ARE UNABLE TO AGREE WITH THE SAID VIEW, AS IN OUR OPINION, IT IS TOO GENERAL IN NATURE. THE ASSESSEES MAY PLACE RELIANCE ON A NUMBER OF CASE LAWS, BOTH RELEVANT AND IRRELEVANT . IN THAT KIND OF SITUATION, IN OUR VIEW, THE TRIBUNAL CAN BE FOUND FAULT WITH ONLY IF IT FAI LED TO CONSIDER RELEVANT CASE LAWS HAVING DIRECT OR AT LEAST SOME REMOTE NEXUS WITH THE ISSUE UNDER CONSIDERATION. THE FOLLOWING OBSERVATIONS MADE BY HONBLE MADHYA PRADESH HIGH CO URT IN THE CASE OF BRIGHT AUTOMATIVE AND PLASTICS LTD (SUPRA) ARE VERY MUCH RELEVANT:- NEEDLESS TO OBSERVE, THE TRIBUNAL WILL DECIDE THE APPEAL AFTER NARRATING THE FULL RELEVANT FACTS NECESSARY FOR THE DISPOSAL OF TWO QUESTIONS, LEGAL ISSUES GOVERNING THE QUESTIONS AND THEN ASSIGN THEIR REASONING WITH REFERENCE TO A NY CASE LAW ON THE SUBJECT HAVING ITS APPLICATION TO THE QUESTION. IN THE INSTANT CASES, IT IS NOT THE CONTENTION OF T HE ASSESSEE THAT THE TRIBUNAL DID NOT GIVE ANY REASON FOR DECIDING THE ISSUES AGITATED BEFORE IT. IN FACT, THE TRIBUNAL HAS DEALT IN DETAIL M.P. NOS.142-145/COCH/2013 3 WITH REGARD TO THE FACTS SURROUNDING THE ISSUE, ARG UMENTS OF THE COUNSELS, VIEWS EXPRESSED BY THE TAX AUTHORITIES AND DECISION TAKEN BY THE TR IBUNAL ALONG WITH THE REASONING. THE VARIOUS CASE LAWS RELIED UPON BY THE ASSESSEE WERE LISTED OUT, THEY WERE CONSIDERED AND FOUND THAT THEY ARE NOT APPLICABLE TO THE FACTS OF THE INSTANT CASE, I.E., THEY DID NOT HAVE APPLICATION TO THE QUESTIONS UNDER CONSIDERATION. 3.3 WE MAY, FOR THE SAKE OF CLARITY, DISCUSS ONE INSTANT. IN PARAGRAPHS 12 TO 13.1 OF THE ORDER, THE TRIBUNAL HAS CONSIDERED AN ISSUE RELATIN G TO THE CASH CREDIT ADDITION MADE U/S 68 OF THE ACT. THE ASSESSEE PLACED RELIANCE ON THE DE CISION OF HONBLE SUPREME COURT IN THE CASE OF CIT VS. LOVELY EXPORTS P LTD S.L.P (CIVIL) NO. 1153 OF 2008 (319 ITR (ST.) 5, 6) TO CONTEND THAT THE ADDITION SHOULD HAVE BEEN MADE IN THE HANDS OF THE CONCERNED CREDITOR. ONE MAY UNDERSTAND THAT THE DECISION WAS RENDERED I N THE CASE OF LOVELY EXPORTS P LTD IN RESPECT OF SHARE APPLICATION MONEY RECEIVED BY A LI MITED COMPANY AND HENCE THE RATIO OF THE SAID DECISION CANNOT BE APPLIED ON A SIMPLE CAS H CREDIT ISSUE EXAMINED IN TERMS OF SEC.68 OF THE ACT. THE ONUS PLACED UPON THE ASSESS EE U/S 68 OF THE ACT TO PROVE THE CASH CREDITS ARE WELL SETTLED. WE MAY ALSO QUOTE ANOTHE R EXAMPLE. THE ASSESSEE PLACED RELIANCE ON THE DECISION OF HONBLE SUPREME COURT I N THE CASE OF CIT VS. K. CHINNATHAMBAN (292 ITR 682) TO CONTEND THAT THE ONUS OF PROVING D EPOSITS LIES UPON THE PERSON IN WHOSE NAME THE DEPOSIT STANDS. IN FACT, THERE WAS NO DIS PUTE WITH REGARD TO THE PROPOSITION LAID DOWN BY THE HONBLE APEX COURT. HOWEVER, IN THE IN STANT CASE, THE ISSUE WAS WITH REGARD TO THE OWNERSHIP OF A BANK ACCOUNT. THE ASSESSIN G OFFICER CAME TO THE CONCLUSION THAT THE DEPOSITS BELONG TO THE ASSESSEE ONLY, AFTER DUL Y CONSIDERING VARIOUS MATERIALS AND ALSO AFTER EXAMINING THE ACCOUNT HOLDER SHRI FRANCIS JOS EPH. HENCE THE ISSUE THAT CAME BEFORE THE TRIBUNAL WAS WHO IS THE REAL OWNER OF THE I MPUGNED BANK ACCOUNT. IT IS KNOWN TO EVERYBODY THAT THE APPARENT OWNER WAS SHRI FRANCIS JOSEPH. HENCE THE TRIBUNAL PROCEEDED TO EXAMINE THE VALIDITY OF THE CONCLUSION S REACHED BY THE TAX AUTHORITIES BY EXAMINING THE FACTS SURROUNDING THE ISSUE. AFTER E XAMINING THE FACTS, ASSESSMENT ORDERS AND THE ORDER OF LD CIT(A), THE TRIBUNAL HAS EXPRES SED ITS VIEW IN DETAIL IN PARAGRAPHS 10 TO 10.6 AND ALSO CONCLUDED THAT THE CASE LAWS RELIED U PON BY THE ASSESSEE ARE NOT APPLICABLE TO THE FACTS OF THE INSTANT CASE. THUS, WE MAY NOTICE THAT THE TRIBUNAL HAS DECIDED THE ISSUE BY CONSIDERING THE FACTS OF THE CASE IN A DETAILED MANNER, SINCE THE FACTS THAT PREVAILED IN THE INSTANT CASE WAS PECULIAR AND THE ISSUE WAS PURELY A QUESTION OF FACT. HENCE, IN OUR VIEW, IT CANNOT BE SAID THAT THE ORDER OF THE TRIBUNAL SUFFE RS FROM MISTAKE ON ACCOUNT OF M.P. NOS.142-145/COCH/2013 4 NON-DISCUSSION OF THE CASE LAWS RELIED UPON BY THE ASSESSEE AND WHICH WERE CONSIDERED AS NOT APPLICABLE BY THE TRIBUNAL. IT IS NOT THE CASE OF THE ASSESSEE THAT THE CASE LAWS RELIED UPON BY HIM WAS NOT CONSIDERED AT ALL. ACCORDINGLY , IN OUR VIEW, THE SHORT FALL, IF ANY, IN NOT DISCUSSING ABOUT THE RELEVANCY/IRRELEVANCY OF THE C ASE LAW CANNOT BE MADE GOOD U/S 254(2) OF THE ACT. 4. THE NEXT MISTAKE POINTED OUT BY THE ASSESSEE IN PARAGRAPH 6 OF THE PETITION IS THAT THE TRIBUNAL HAS OMITTED TO CONSIDER THE DECISION REPOR TED IN 281 CTR 691 IN DISPOSING OF THE GROUND RELATING TO VIOLATION OF PRINCIPLES OF NATUR AL JUSTICE WITH REGARD TO THE STATEMENT RECORDED FROM SHRI FRANCIS JOSEPH ON 05-09-2012 BEH IND THE BACK OF THE ASSESSEE. THIS CONTENTION OF THE ASSESSEE HAS BEEN SPECIFICALLY DE ALT WITH BY THE TRIBUNAL IN PARAGRAPH 10.6 OF THE ORDER BY DULY CONSIDERING THE FACTS SURROUND ING THE ISSUE. THUS, WE NOTICE THAT THE TRIBUNAL HAS ALREADY TAKEN A CONSCIOUS DECISION, WH ICH CANNOT BE REVIEWED U/S 254(2) OF THE ACT. 5. IN PARAGRAPHS 7 TO 10 OF THE PETITION, IT IS POINTED OUT THAT THE TRIBUNAL HAS OMITTED TO CONSIDER CERTAIN FACTS, VIZ., THE REPLY GIVEN BY LD CIT UNDER RIGHT TO INFORMATION ACT TO THE EFFECT THAT THE IMPUGNED BANK ACCOUNT RELATE TO FRA NCIS JOSEPH AND HENCE NO INFORMATION COULD BE GIVEN TO THE ASSESSEE. IT IS ALSO POINTED OUT THAT THE TRIBUNAL DID NOT CONSIDER THE REQUEST MADE FOR CROSS EXAMINATION OF SHRI FRANCIS JOSEPH. THE QUESTION RELATING TO CROSS EXAMINATION HAS BEEN SPECIFICALLY DEALT WITH IN PAR AGRAPH 10.6 OF THE ORDER. AS STATED EARLIER, THE ISSUE CONTESTED IN THIS APPEAL IS ABOU T THE OWNERSHIP OF THE BANK ACCOUNT STANDING IN THE NAME OF SHRI FRANCIS JOSEPH. ON TH E BASIS OF SUBSTANTIVE EVIDENCES GATHERED BY THE TAX AUTHORITIES, THE TRIBUNAL HAS C ONFIRMED THE VIEW EXPRESSED BY LD CIT(A). THE REPLY GIVEN BY LD CIT IN RESPONSE TO THE APPLIC ATION FILED UNDER RTI ACT IS NOT RELATED TO THE ISSUE UNDER CONSIDERATION. HENCE, IN OUR VIEW, THE NON DISCUSSION ABOUT THE OPINION EXPRESSED BY THE LD CIT IN RESPONSE TO THE APPLICAT ION FILED UNDER RTI WOULD NOT RENDER THE ORDER OF THE TRIBUNAL ERRONEOUS. 6. IN PARAGRAPH 11 OF THE PETITION, IT IS POINTE D OUT THAT THE TRIBUNAL HAS OMITTED TO ADJUDICATE THE GROUNDS NUMBERED AS 3, 8, 9, 10, 11 AND 12. BEFORE PROCEEDING TO ADDRESS THIS POINT, WE FEEL IT PERTINENT TO EXTRACT BELOW R ULE 8 OF APPELLATE TRIBUNAL RULES, 1963. M.P. NOS.142-145/COCH/2013 5 8. EVERY MEMORANDUM OF APPEAL SHALL BE WRITTEN I N ENGLISH AND SHALL SET FORTH, CONCISELY AND UNDER DISTINCT HEADS , THE GROUNDS OF APPEAL WITHOUT ANY ARGUMENT OR NARRATIVE ; AND SUCH GROUNDS SHALL BE NUMBERED CONSECUTIVELY. IT IS PERTINENT TO MENTION HERE THAT THE GROUNDS UR GED BY THE ASSESSEE WERE NOT CONCISE AND THEY ALSO INCLUDED ARGUMENTS AND NARRATIVES, WHICH WERE IN GROSS VIOLATION OF RULE 8 OF THE APPELLATE TRIBUNAL RULES, 1963 EXTRACTED ABOVE. HE NCE, IN PARAGRAPH 6 OF THE ORDER, THE TRIBUNAL HAS SPECIFICALLY OBSERVED THAT THE ASSESSE E HAS TAKEN MANY GROUNDS AND ACCORDINGLY LISTED OUT THE ISSUES THAT REQUIRE ADJU DICATION. THUS, THE GROUNDS NUMBERED AS 3, 8, 9, 10, 11 AND 12 WERE ALL RELATED TO THE ISSU ES LISTED OUT IN PARAGRAPH 6 OF THE ORDER OF THE TRIBUNAL AND THEY HAVE BEEN DULY CONSIDERED WHI LE ADJUDICATING THE RELEVANT ISSUES. HENCE, THE ASSESSEE IS NOT CORRECT IN STATING THAT THE TRIBUNAL HAS OMITTED TO ADJUDICATE THE GROUNDS CITED ABOVE. 7. IN PARAGRAPH 12 OF THE PETITION, THE ASSESSEE IS AGAIN DISCUSSING ABOUT THE VIOLATION OF PRINCIPLES OF NATURAL JUSTICE, WHICH HAS ALREADY BEEN DISCUSSED IN THE PRECEDING PARAGRAPHS. 8. IN PARAGRAPH 13 TO 15 OF THE PETITION, THE AS SESSEE POINTS OUT THAT THE TRIBUNAL HAS NOT ADDRESSED THE PLEA OF THE ASSESSEE TO SUMMON TH E MANAGER OF FEDERAL BANK IN ORDER TO ASCERTAIN ABOUT THE TRUE OWNER OF THE IMPUGNED BANK ACCOUNT. THE ASSESSEE HAS ALSO POINTED OUT THAT TRIBUNAL HAS NOT CONSIDERED THE DE CISION OF HONBLE SUPREME COURT REPORTED IN 125 ITR 713. WE HAVE ALREADY STATED THAT THE IS SUE CONSIDERED BY THE TRIBUNAL WAS ABOUT THE OWNERSHIP OF A BANK ACCOUNT, I.E, THE CAS E OF THE REVENUE WAS THAT THE APPARENT OWNER WAS NOT THE REAL OWNER. THE SAID ISSUE WAS A DJUDICATED BY THE TRIBUNAL BY CONSIDERING THE FACTS SURROUNDING THE ISSUE. THE P LEA OF THE ASSESSEE WAS THAT THE MANAGER OF THE FEDERAL BANK CAN DEPOSE ABOUT THE OW NERSHIP, IF HE IS SUMMONED. THE MANNER AND METHOD OF INVESTIGATION IS DECIDED BY TH E TAX AUTHORITIES AND IN FACT, IT IS THEIR PREROGATIVE TO DECIDE ABOUT THE MODALITIES. ON THE BASIS OF FACTS GATHERED BY THEM, THE TRIBUNAL ALSO DID NOT FIND ANY INFIRMITY IN THE DEC ISION REACHED BY THEM. IN THE ASSESSMENT PROCEEDINGS, IT IS THE RESPONSIBILITY OF THE ASSESS EE TO DISPROVE THE VIEW ENTERTAINED BY THE ASSESSING OFFICER ON THE BASIS OF MATERIALS GATHERE D BY HIM. IF ACCORDING TO THE ASSESSEE, THE RECORDS KEPT BY THE BANK MANAGER WOULD HAVE HEL PED TO DECIDE ABOUT THE OWNERSHIP OF M.P. NOS.142-145/COCH/2013 6 THE BANK ACCOUNT, HE SHOULD HAVE GATHERED THEM FROM THE BANK AND PRODUCED THE SAME BEFORE THE AO. EVEN OTHERWISE, IN OUR VIEW, THE B ANK AUTHORITIES CAN DEPOSE ABOUT THE APPARENT ONLY, WHEREAS, THE CASE OF THE REVENUE I S THAT THE APPARENT IS NOT REAL. THE TRIBUNAL HAS HELD THE REVENUE HAS SUBSTANTIATED THE IR CONTENTIONS WITH ADEQUATE MATERIALS. THE CASE LAW RELIED UPON BY THE ASSESSEE IN THIS RE GARD WAS RELATED TO A SOLITARY TRANSACTION OF TELEGRAPHIC TRANSFER BY AN EMPLOYEE OF ONE OFFIC E OF ASSESSEE TO EMPLOYEE OF ANOTHER OFFICE. HENCE, UNDER THE PECULIAR FACTS PREVAILING IN THAT CASE, THE HONBLE SUPREME COURT HELD THAT THE EVIDENCES CONSIDERED BY THE TRIBUNAL CANNOT BE CONSIDERED AS MATERIAL AND THE TRUE FACTS COULD HAVE BEEN ASCERTAINED BY EXAMINING THE BANK MANAGER. THE HONBLE APEX COURT HAS NOT LAID DOWN ANY PROPOSITION THAT IT IS NECESSARY TO EXAMINE THE MANAGER OF THE BANK WITH REGARD TO THE DEPOSITS MADE INTO THE BANK ACCOUNT. WE HAVE ALREADY NOTICED THAT THE FACTS PREVAILING IN THE INSTANT CASE ARE D IFFERENT AND HENCE, IN OUR VIEW, NON-DISCUSSION OF THE CASE LAW REPORTED IN 125 ITR 713 WOULD NOT RENDER THE ORDER ERRONEOUS. 9. IN PARAGRAPH 16 TO 22, THE ASSESSEE IS DISCUS SING ABOUT THE FINDINGS AND DECISIONS RENDERED BY THE TRIBUNAL ON VARIOUS ISSUES. ACCORD ING TO THE ASSESSEE, THERE ARE MISTAKES IN THE SAID FINDINGS AND DECISIONS GIVEN BY THE TRI BUNAL. IT IS SETTLED PROPOSITION OF LAW THAT THE TRIBUNAL IS NOT EMPOWERED TO REVIEW ITS FINDING S AND DECISIONS U/S 254(2) OF THE ACT. 10. IT IS PERTINENT TO NOTE THAT EACH OF THE MISCEL LANEOUS PETITIONS CONTAINS 22 PARAGRAPHS AND EACH OF THEM RUN INTO SEVEN PAGES. IT IS A WEL L SETTLED PROPOSITION OF LAW THAT, IF THE ERROR SOUGHT TO BE POINTED OUT HAS TO BE ESTABLISHE D IN A LONG DRAWN PROCESS OF REASONING WITH NUMBER OF ARGUMENTS, THEN THEY CANNOT BE CONSI DERED AS A MISTAKE APPARENT FROM RECORD. NEVERTHELESS, WE HAVE ADDRESSED ALL THE PO INTS URGED IN THE MISCELLANEOUS PETITION AND DO NOT FIND ANY MERIT THEREIN. 11. IN VIEW OF THE FOREGOING DISCUSSIONS, WE DO NOT FIND MERIT IN THE PETITIONS FILED BY THE ASSESSEE AND ACCORDINGLY WE DISMISS ALL OF THEM. M.P. NOS.142-145/COCH/2013 7 12. IN THE RESULT, ALL THE MISCELLANEOUS APPLICA TIONS FILED BY THE ASSESSEE ARE DISMISSED. PRONOUNCED ACCORDINGLY ON 07-02-20 14. SD/- SD/- (N.R.S.GANESAN) (B.R.BASKARAN) JUDICIAL MEMBER ACC OUNTANT MEMBER PLACE: KOCHI DATED: 7TH FEBRUARY, 2014 GJ COPY TO: 1. JOSE KURUVINAKUNNEL, PARTNER, HOTEL MAYURA, POOV ARANI, PALA, KOTTAYAM. -2. THE INCOME-TAX OFFICER, WARD-2, KOTTAYAM. 3. THE COMMISSIONER OF INCOME-TAX(APPEALS), TIRUPATI CAMP KOCHI. 4. THE COMMISSIONER OF INCOME-TAX, KOTTAYAM. 5. D.R., I.T.A.T., COCHIN BENCH, COCHIN. 6. GUARD FILE. BY ORDER (ASSIST ANT REGISTRAR) I. T.A.T, COCHIN